Airborne 08.18.17

Led by the Aeronautical
Repair Station Association (ARSA), a broad-based aviation industry
coalition submitted comments in response to the Federal Aviation
Administration's (FAA) proposed rule to drastically expand the
scope of its Antidrug and Alcohol Prevention Program.

"Thirteen aviation industry groups and companies endorsed ARSA's
comments and joined as signatories," according to ARSA Executive
Director Sarah MacLeod. "The aviation world is clearly united in
opposition to this unnecessary, costly and misguided FAA
proposal."

The proposed rule would require non-certificated maintenance
subcontractors (NCMS) working for FAA-certificated repair stations
to participate in an FAA-approved drug and alcohol screening
program if the articles in question are ultimately installed on air
carrier aircraft.

NCMS businesses provide technical services in support of
aviation and other industries such as metal finishing, dry
cleaning, machining and heat treating. They are not subject to
direct regulatory oversight because they cannot take airworthiness
responsibility for the work they perform under FAA maintenance
regulations. Certificated repair stations remain responsible for
the airworthiness of any maintenance function performed by their
non-certificated subcontractors. In addition, all maintenance
employees of the airlines and their direct contractors are already
covered by the FAA's drug and alcohol rules.

ARSA asked the FAA to
withdraw the proposed rule in light of evidence that the agency
vastly underestimated its economic impact. Based on surveys the
Association conducted over the past two months, noted aviation
economist Darryl Jenkins determined that as many as 22,000 NCMS
from a variety of industries would find themselves subject to the
new rule. This number starkly contrasts with the FAA's estimate of
297 companies that would be impacted.

The survey results reinforce the Association's concern that a
substantial number of NCMS would decline to serve aviation
customers if the proposed rule goes into effect -- shrinking
competition and driving up costs.

The Joint Industry Comments also noted the FAA's failure to
consider the safety mechanisms already in place to protect the
flying public. The current regulatory scheme ensures the
airworthiness of articles and products maintained by the aviation
industry. Therefore, the FAA's proposal is unnecessary, costly and
burdensome to the small businesses that would be primarily
impacted.

ARSA will continue its efforts to prevent the implementation of
this duplicative and economically damaging rule.